ACCEPTED
04-14-00758-CV
FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
2/5/2015 8:17:50 AM
KEITH HOTTLE
CLERK
NO. 04-14-00758-CV
FILED IN
IN THE COURT OF APPEALS 4th COURT OF APPEALS
SAN ANTONIO, TEXAS
FOURTH COURT OF APPEALS DISTRICT OF TEXAS
SAN ANTONIO, TEXAS 02/5/2015 8:17:50 AM
KEITH E. HOTTLE
Clerk
JOHN A. LANCE, DEBRA L. LANCE,
F.D. FRANKS AND HELEN FRANKS
APPELLANTS
V.
JUDITH AND TERRY ROBINSON, GARY AND BRENDA FEST,
VIRGINIA GRAY, BUTCH TOWNSEND AND
BEXAR-MEDINA-ATASCOSA COUNTIES WATER CONTROL AND
IMPROVEMENT DISTRICT NO. 1
APPELLEES
APPELLANTS’ UNOPPOSED FIRST
MOTION FOR EXTENSION OF TIME TO FILE APPELLANTS’ BRIEF
TO THE HONORABLE JUSTICES OF THE COURT:
JOHN A LANCE, DEBRA L. LANCE, F.D. FRANKS and HELEN
FRANKS, Appellants, submit their First Unopposed Motion for Extension of Time
to File Appellants’ Brief and in support of this motion state as follows:
1. Appellants’ Brief is due February 5, 2015.
2. This motion is filed prior to the expiration of this due date.
3. The undersigned has conferred with the attorneys for Appellees and
this motion is unopposed.
4. Appellants request an additional thirty (30) days to file their
Appellants’ Brief, extending the time to March 9, 2015 (the first business day
following the expiration of 30 days).
5. No extension has previously been granted.
6. The undersigned is responsible for the preparation of Appellants’
Brief. The undersigned has been engaged in discovery and complex motion
practice in Union Pacific Railroad Company v. Fiberlight, LLC, Eagle 1 Resources
and David L. Thomas, Cause No. 2014-CI-08880, pending in district court in
Bexar County; responding to a petition for review in Sloan v. Law Office of Oscar
C. Gonzalez, Inc., No. 14-1015; preparing multiple summary judgment responses
in Dimmit Wood Properties, Ltd. v. Chesapeake Exploration, LLC, et. al, No. 13-
10-12107-DCV-AJA, pending in the 365th District Court, Dimmit County; and
preparing for trial in Sharif & Munir Enterprises, Inc. et al v. Laguna Madre
Construction, Inc. and Hope Lumber & Supply Company, No. 2012-DCL-6341-G,
pending in the 404th District Court, Cameron County. This extension request is
not filed for purposes of delay.
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PRAYER
Appellants ask this Court to grant their motion extending the deadline to file
their Appellants’ Brief to March 9, 2015.
Respectfully submitted,
Cynthia Cox Payne
Texas Bar No. 24001935
P.O. Box 1178
1118 Main Street
Bandera, TX 78003
(830) 796.7030 – Phone
(830) 796.7945 – Fax
cpayne@paynelawfirm.net
John D. Payne
Texas Bar No. 15658500
P.O. Box 1178
1118 Main Street
Bandera, TX 78003
(830) 796.7030 – Phone
(830) 796.7945 – Fax
jpayne@paynelawfirm.net
LAW OFFICE OF DAN POZZA
239 E. Commerce Street
San Antonio, TX 78205
(210) 226-8888 – Phone
(210) 224-6373 – Fax
danpozza@yahoo.com
/s/Dan Pozza
State Bar No. 16224800
ATTORNEYS FOR APPELLANTS
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CERTIFICATE OF SERVICE
I hereby that a true and correct copy of the above and foregoing document
has been delivered via e-mail transmission on this 5th day of February, 2015, to:
Stephan B. Rogers
Ross S. Elliott
Rogers & Moore
309 Water Street, Suite 114
Boerne, Texas 78006
Attorney for Plaintiffs
srogerslaw@gmail.com
Attorneys for Judith and Terry Robinson, Gary and
Brenda Fest, Virginia Gray and Butch Townsend
Edward Hecker
GOSTOMSKI & HECKER
607 Urban Loop
San Antonio, Texas 78204
ed@ghlawyers.net
Attorney for Bexar-Medina-Atascosa Counties
Water Control and Improvement District No. 1
/s/Dan Pozza
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